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In the United States District Court for the Eastern District of Texas Marshall Division

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In the United States District Court for the Eastern District of Texas Marshall Division Case 2:09-cv-00147-TJW Document 1 Filed 05/12/09 Page 1 of 24 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION API TECHNOLOGIES, LLC Plaintiff, v. Civil Action No. _______________ (1) FACEBOOK, INC.; (2) AMAZON.COM, INC.; JURY TRIAL DEMANDED (3) AMAZON WEB SERVICES LLC; (4) AOL LLC; (5) MAPQUEST, INC.; (6) BEBO, INC.; (7) TRUVEO, INC.; (8) BEST BUY CO. INC.; (9) CBS CORPORATION; (10) CBS INTERACTIVE INC.; (11) CBS INTERACTIVE MEDIA INC.; (12) CNET INVESTMENTS, INC.; (13) CNET NETWORKS, INC.; (14) LAST.FM LIMITED; (15) THE DUN & BRADSTREET CORPORATION; (16) HOOVER’S, INC.; (17) GOOGLE INC.; (18) ANDROID, INC.; (19) THOMSON REUTERS CORPORATION; (20) THOMSON REUTERS PLC; (21) THOMSON REUTERS U.S. INC.; (22) THOMSON REUTERS U.S.A. INC.; (23) REUTERS AMERICA, LLC; and (24) YAHOO! INC., Defendants. ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT This is an action for patent infringement in which Plaintiff, API Technologies, LLC, complains against the Defendants Facebook, Inc.; Amazon.com, Inc.; Amazon Web Services LLC; AOL LLC; Mapquest, Inc.; Bebo, Inc.; Truveo, Inc.; Best Buy Co. Inc.; CBS Corporation; CBS Interactive Inc.; CBS Interactive Media Inc.; CNET Investments, Inc.; CNET Networks, Case 2:09-cv-00147-TJW Document 1 Filed 05/12/09 Page 2 of 24 Inc.; Last.FM Limited; The Dun & Bradstreet Corporation; Hoover’s, Inc.; Google Inc.; Android, Inc.; Thomson Reuters Corporation; Thomson Reuters PLC; Thomson Reuters U.S. Inc.; Thomson Reuters U.S.A. Inc.; Reuters America, LLC; and Yahoo! Inc. (collectively the “Defendants”), as follows: PARTIES 1. API Technologies, LLC (“API”) is a Texas limited liability company with its principal place of business at 207C N Washington Street, Marshall, TX. 2. On information and belief, Defendant Facebook, Inc. (“Facebook”) is a Delaware corporation with its principal place of business at 471 Emerson Street, Palo Alto, California 94301. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 3. On information and belief, Defendant Amazon.com, Inc. (“Amazon”) is a Delaware corporation with its principal place of business at 1200 12th Avenue South Suite 1200, Seattle, WA 98144. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 4. On information and belief, Defendant Amazon Web Services LLC (“AWS”) is a Delaware corporation with its principal place of business at 1200 12th Avenue South Suite 1200, Seattle, WA 98144. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 5. On information and belief, Defendant AOL LLC (“AOL”) is a Delaware corporation with its principal place of business at 770 Broadway, New York, NY 10003. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 2 Case 2:09-cv-00147-TJW Document 1 Filed 05/12/09 Page 3 of 24 6. On information and belief, Defendant Mapquest, Inc. (“Mapquest”) is a Delaware corporation with its principal place of business at 555 17th Street, Suite 1600, Denver, Colorado 80202. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 7. On information and belief, Defendant Bebo, Inc. (“Bebo”) is a Delaware corporation with its principal place of business at 795 Folsom St Fl 6, San Francisco, 94107. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 8. On information and belief, Defendant Truveo, Inc. (“Truveo”) is a Delaware corporation with its principal place of business at 333 Bush Street, 23rd Floor, San Francisco, CA 94104. This Defendant has appointed Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 9. On information and belief, Defendant Best Buy Co. Inc. (“Best Buy”) is a Minnesota corporation with its principal place of business at 7601 Penn Ave. South, Richfield, MN 55423. This Defendant has appointed CT Corporation System Inc., 100 S 5th Street #1075, Minneapolis, MN 55402 as its agent for service of process. 10. On information and belief, Defendant CBS Corporation (“CBS”) is a Delaware corporation with its principal place of business at 51 W. 52nd Street, New York, NY 10019. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808 as its agent for service of process. 11. On information and belief, Defendant CBS Interactive Inc. (“CBS Interactive”) is a Delaware corporation with its principal place of business at 51 W. 52nd Street, New York, NY 3 Case 2:09-cv-00147-TJW Document 1 Filed 05/12/09 Page 4 of 24 10019. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808 as its agent for service of process. 12. On information and belief, Defendant CBS Interactive Media Inc. (“CBS Media”) is a Delaware corporation with its principal place of business at 51 W. 52nd Street, New York, NY 10019. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808 as its agent for service of process. 13. On information and belief, Defendant CNET Investments, Inc (“CNET”) is a Delaware corporation with its principal place of business at 51 W. 52nd Street, New York, NY 10019. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808 as its agent for service of process. 14. On information and belief, Defendant CNET Networks, Inc. (“CNET Networks”) is a Delaware corporation with its principal place of business at 51 W. 52nd Street, New York, NY 10019. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808 as its agent for service of process. 15. On information and belief, Defendant Last.FM Limited (“Last.FM”) is a UK corporation with its principal place of business at 51 W. 52nd Street, New York, NY 10019. This Defendant may be served at 51 W. 52nd Street, New York, NY 10019 or at 1-11 Baches Street, London, N1 6DL via an officer, a managing or general agent, or any other agent authorized by appointment or by law to receive service of process. 16. On information and belief, Defendant The Dun & Bradstreet Corporation (“D&B”) is a Delaware corporation with its principal place of business at 103 JFK Parkway, Short Hills, NJ 07078. This Defendant has appointed The Corporation Trust Company, 4 Case 2:09-cv-00147-TJW Document 1 Filed 05/12/09 Page 5 of 24 Corporation Trust Center, 1209 Orange Street, Wilmington, DE 19801as its agent for service of process. 17. On information and belief, Defendant Hoover’s, Inc. (“Hoover’s”) is a Delaware corporation with its principal place of business at 5800 Airport Blvd., Austin, TX 78752-3812. This Defendant has appointed The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, DE 19801as its agent for service of process. 18. On information and belief, Defendant Google Inc. (“Google”) is a Delaware corporation with its principal place of business at 1600 Amphitheater Parkway, Mountain View, California 94043. This Defendant has appointed The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801 as its agent for service of process. 19. On information and belief, Defendant Android, Inc. (“Android”) is a Delaware corporation with its principal place of business at 1600 Amphitheater Parkway, Mountain View, California 94043. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 20. On information and belief, Defendant Thomson Reuters Corporation (“Thomson”) is a Canada corporation with its principal place of business at 3 Times Square, 17th Floor New York, NY 10036. This Defendant may be served at 3 Times Square, 17th Floor New York, NY 10036 via an officer, a managing or general agent, or any other agent authorized by appointment or by law to receive service of process. 21. On information and belief, Defendant Thomson Reuters PLC (“Thomson PLC”) is a UK corporation with its principal place of business at The Thomson Reuters Building South Colonnade Canary Wharf, London, ENG E14 5EP, United Kingdom. This Defendant may be 5 Case 2:09-cv-00147-TJW Document 1 Filed 05/12/09 Page 6 of 24 served at The Thomson Reuters Building South Colonnade Canary Wharf, London, ENG E14 5EP, United Kingdom via an officer, a managing or general agent, or any other agent authorized by appointment or by law to receive service of process. 22. On information and belief, Defendant Thomson Reuters U.S. (“Thomson US”) is a Delaware corporation with its principal place of business at 3 Times Square, 17th Floor New York, NY 10036. This Defendant has appointed Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 23. On information and belief, Defendant Thomson Reuters U.S.A. Inc. (“Thomson USA”) is a Delaware corporation with its principal place of business at 3 Times Square, 17th Floor New York, NY 10036. This Defendant has appointed The Prentice-Hall Corporation Systems, Inc., 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. 24. On information and belief, Defendant Reuters America, LLC (“Reuters”) is a Delaware corporation with its principal place of business at 3 Times Square, 17th Floor New York, NY 10036. This Defendant has appointed The Prentice-Hall Corporation System, Inc., 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process.
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